Parella, et al. v. Retirement of RI

CourtDistrict Court, D. New Hampshire
DecidedFebruary 27, 1998
DocketCV-96-434-M
StatusPublished

This text of Parella, et al. v. Retirement of RI (Parella, et al. v. Retirement of RI) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parella, et al. v. Retirement of RI, (D.N.H. 1998).

Opinion

Parella, et al. v. Retirement of RI CV-96-434-M 02/27/98 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Gaetano Parella, Mildred Tantimonaco, John Gilgun, Helena McDermott, and Delores Ferry, on behalf of themselves and others similarly situated.

Plaintiffs

v. N.H. Civil No. 96-434-M R.I. Civil No. 95-358

Retirement Board of the Rhode Island Employees' Retirement System, et a l .,

_____ Defendants.

O R D E R

After recovering vested pension benefits which were

unconstitutionally withheld from them (albeit only temporarily)

and securing an award of prejudgment interest, plaintiffs now

move for an award of attorneys' fees pursuant to 42 U.S.C. §

1988. Defendants object.

Factual Background

The factual and procedural history of this case is discussed

at length in the court's order dated March 31, 1997.

Nevertheless, a brief review of the relevant facts and history

might be helpful. In 1994 the State of Rhode Island and the Internal Revenue

Service entered into an agreement aimed at preserving the

gualified trust status of the Employees' Retirement System of the

State of Rhode Island ("ERS"). See generally 26 U.S.C. § 401(a)

(outlining reguirements for maintaining the gualified tax status

of pension plans). Pursuant to that agreement, the Rhode Island

Legislature capped state legislators' annual pensions at $10,000

— the maximum amount tax gualified pension plans were then

permitted to pay under 26 U.S.C. § 415(b). See R.I. Gen. Laws

§§ 36-8-20(e) and 36-10-10.1(e) (the "Act")- The Act became

effective in July 1995.

Plaintiffs are members of a class consisting of retired

Rhode Island legislators and surviving spouses of legislators

who, prior to July 1995, were receiving annual retirement

benefits in excess of $10,000. Seeking to enjoin enforcement of

the Act's $10,000 annual limitation, plaintiffs brought this

action in the United States District Court for the District of

Rhode Island, naming as defendants the Retirement Board of the

Rhode Island Employees' Retirement System (the "Board") and Nancy

Mayer and Joann Flaminio, in their official capacities. See 42

U.S.C. § 1983. Among other things, plaintiffs claimed that the

2 Act deprived them of property without due process of law and just

compensation, in violation of the United States Constitution.

The court denied plaintiffs' request for an order

temporarily restraining defendants from implementing or enforcing

the Act. Following an evidentiary hearing, the court denied

plaintiffs' request for a preliminary injunction, concluding that

plaintiffs had failed to demonstrate that they would suffer

irreparable injury in the absence of a preliminary injunction.

The court noted, however, that plaintiffs were likely to prevail

on the merits. Shortly thereafter, the case was transferred to

this district upon recusal of the judges sitting in the District

of Rhode Island.

In August of 1996 Congress enacted the Small Business Job

Protection Act of 1996 which, among other things, amended § 415

of the Internal Revenue Code, retroactively to December 31, 1994.

The parties agreed that the amendments to § 415 made it possible

for ERS and the Board to reinstate plaintiffs' full vested

retirement benefits and repay all amounts previously withheld,

without risk that such payments might adversely affect ERS's

federal tax status. Accordingly, on September 6, 1996,

plaintiffs filed a motion for interim relief, seeking an order

3 compelling defendants to actually resume paying each class member

the full vested monthly retirement benefit to which he or she was

entitled and to promptly pay retirement benefits withheld during

the pendency of this litigation. Defendants did not oppose the

reguested relief. Approximately two months later, defendants

resumed paying plaintiffs their full vested retirement benefits

and paid all past benefits which had been withheld (totaling

nearly $850, 000) .

Subseguently, plaintiffs moved for an order compelling

defendants to pay them additional compensation, in the form of

prejudgment interest. They argued that such an award was

necessary to fully and adeguately compensate them for the harm

suffered during the period defendants wrongfully withheld that

part of their annual pension benefits exceeding $10,000. The

court agreed, concluding that:

the Act, as applied, unconstitutionally deprived plaintiffs of "property" without just compensation, in violation of the Fifth Amendment. The relevant factors identified by the Supreme Court in Penn Central, supra, support the conclusion that plaintiffs suffered an unconstitutional deprivation of property: the Act, as applied, had a substantial adverse "economic impact" upon plaintiffs; it interfered with plaintiffs' legitimate, distinct investment-backed expectations, Ruckelshaus v. Monsanto, 4 67 U.S. at 1011; and the character of the governmental action, although defying precise definition, is more akin to a "physical invasion" or confiscation of plaintiffs' property.

4 rather than simply a readjustment of economic benefits and burdens (e.g., this is not analogous to the exercise of the state's power to levy taxes nor is it a situation in which the state could reasonably conclude that taking plaintiffs' property was reasonably necessary to promote the health, safety, morals, or general welfare of the public.).

Parella v. Retirement Board of the R.I. Employees' Retirement

System, No. 96-358-M, slip op. at 12 (D.N.H. March 31, 1997).1

The court then concluded that while ERS (acting through the

Board) might be liable as a state actor under 42 U.S.C. § 1983,

it was not entitled to immunity under the Eleventh Amendment.

Id., at 21 ("Having considered all of the relevant factors,

including those identified by the Supreme Court and the Court of

1 Curiously, in a series of footnotes, defendants repeatedly argue that the "taking" issue was a "new issue . . . not [previously] made known to the parties." Defendants' Objection at 10 n.12. See also Defendants' Objection at 4 n.4 ("That issue had not been briefed by the parties . . .."); Defendant's Objection at 9 n.ll ("In fact, the court did not address the issues raised in the parties' summary judgment motions, but rather a new issue the Court raised sua sponte .") .

Defendants seem to imply that they were caught unawares when the court ruled that the Act, as applied, effected an unconstitutional taking. The basis for that claim is, however, a mystery. In light of the allegations contained in plaintiffs' complaint and the legal arguments presented in their motion for summary judgment specifically addressing the "taking" issue, defendants' claims are, at best, ill-supported. See, e.g.. Amended Class Action Complaint for Declaratory and Injunctive Relief at paras. 3, 33-35; Plaintiffs' Memorandum of Law in Support of Motion for Summary Judgment at 31-35.

5 Appeals, the court concludes that ERS is not an alter ego or arm

of the State of Rhode Island. Accordingly, neither ERS nor the

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